50 signatures reached
To: TO: General Public
New Mexico Cannabis Justice Project
Members of the Cannabis Control Division,
This set of revised rules was supposed to include changes in response to public comment provided on the first hearing that took place on June 29th. Many of those concerns were over water rights, excessive water use and industry access for locals. Despite the addition of some social equity language and minor changes to regulations, this proposed set still does not address issues mentioned and in fact, strengthens and prioritizes existing and well-financed operators. The lack of substance in the equity language, the addition of an unlawful variance mechanism, mediocre water protections, a change in language regarding felony convictions and the inability to report illegal and unlawful activities of producers are all evidences of ways the industry continues to have a stronghold over locals. It is important that regulators and agencies remain focused on protecting and prioritizing water and New Mexican residents over out-of-state investors coming to capitalize off of a struggling economy.
In response to these concerns I ask for the following:
- Substantial and meaningful social equity provisions that include timelines, metrics and requirements as required by the CRA.
- Specific exemptions and contingencies for small farmers/microbusinesses.
- The removal of the unlawful variance mechanism which would allow applicant or licensee to evade water, equity, plant limits and environmental requirements.
- Stronger water protections to include: online notice of applications submitted to better prepare communities, a requirement for the CCD to consult with OSE and/or water provider to prove legitimacy, estimated energy use with water and conservation plans, and water use requirements for immature plants.
- Inclusion and access to the industry for individuals with a prior felony conviction for possession of a controlled substance.
- The development of protocols and procedures to report water theft, use of weapons on licensed cannabis premises, use of drinking water for agricultural use, excess rubbage, transportation of cannabis through federal lands, human trafficking, and threats on community resources/individuals as has been evidenced by existing medical producers.
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This set of revised rules was supposed to include changes in response to public comment provided on the first hearing that took place on June 29th. Many of those concerns were over water rights, excessive water use and industry access for locals. Despite the addition of some social equity language and minor changes to regulations, this proposed set still does not address issues mentioned and in fact, strengthens and prioritizes existing and well-financed operators. The lack of substance in the equity language, the addition of an unlawful variance mechanism, mediocre water protections, a change in language regarding felony convictions and the inability to report illegal and unlawful activities of producers are all evidences of ways the industry continues to have a stronghold over locals. It is important that regulators and agencies remain focused on protecting and prioritizing water and New Mexican residents over out-of-state investors coming to capitalize off of a struggling economy.
In response to these concerns I ask for the following:
- Substantial and meaningful social equity provisions that include timelines, metrics and requirements as required by the CRA.
- Specific exemptions and contingencies for small farmers/microbusinesses.
- The removal of the unlawful variance mechanism which would allow applicant or licensee to evade water, equity, plant limits and environmental requirements.
- Stronger water protections to include: online notice of applications submitted to better prepare communities, a requirement for the CCD to consult with OSE and/or water provider to prove legitimacy, estimated energy use with water and conservation plans, and water use requirements for immature plants.
- Inclusion and access to the industry for individuals with a prior felony conviction for possession of a controlled substance.
- The development of protocols and procedures to report water theft, use of weapons on licensed cannabis premises, use of drinking water for agricultural use, excess rubbage, transportation of cannabis through federal lands, human trafficking, and threats on community resources/individuals as has been evidenced by existing medical producers.
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Why is this important?
The NM Cannabis Justice Project coalition feels strongly about the need for public input as these rules will affect NM’s agriculture for generations to come. We continue to ask for transparency as the community advisory board did receive the opportunity to contribute to these particular set of rules, and the current rules hold a greater threat of unlawful water transfers out of small farms, do not acknowledge NM’s vibrant and longstanding cultures, and uses loop holes for large producers to ask for variances on water leasing rights.
How it will be delivered
Signatures will be emailed.